Transfer pricing (TP) is based on many principles - the essential one is the Arm ́s Length Principle (ALP), In this respect, the term "associated persons" is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied, The aim of the paper is to...

Organisations these days are growing rapidly, and both operational activities and business networks tend to use business unit strategies to overcome operational complexity. This constantly growing environment can significantly impact multinational transfer pricing practices. The research aims to...

We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

To combat firms exploiting transfer pricing as a tool for tax avoidance, the Organisation for Economic Co-operation and Development (OECD) introduced the Base Erosion and Profit Shifting Action 13 (BEPS 13), enhancing tax transparency and the exchange of information with tax authorities....

This paper reflects the tabled novel framework for corporate taxation in the European Union, founded on the Formulary Apportionment methodology and envisaged inclusion of intangible assets in the allocation formula. The objective is to simulate the variation between the currently used Separate...